State of North Dakota v. Jered Mark Petersen

Summary

The North Dakota Supreme Court reversed a criminal judgment entered after Jered Mark Petersen conditionally pleaded guilty to actual physical control of a vehicle while under the influence of alcohol. The Court held that officers unlawfully searched Petersen’s semi-truck by opening the passenger door and entering without first attempting to obtain a response from outside the vehicle, and that the community caretaker and inevitable discovery doctrines did not apply. The case was remanded to permit Petersen to withdraw his guilty plea and for further proceedings.

Holdings

1. Law enforcement conducted an unreasonable warrantless search when it opened Petersen’s semi-truck door and stepped onto the running boards to gather information without first attempting to obtain a response from outside the vehicle.
2. The inevitable discovery doctrine did not apply because the State failed to prove how the evidence would have been legally discovered without the unlawful entry.
3. The order denying suppression and the criminal judgment were reversed, and the case was remanded to permit Petersen to withdraw his guilty plea and for further proceedings consistent with the opinion.

Questions Presented

1. Whether officers conducted an unreasonable warrantless search by opening the door of Petersen’s parked semi-truck and stepping onto the running boards without first attempting to obtain a response from outside the vehicle.
2. Whether the community caretaking exception to the warrant requirement justified the officers’ warrantless entry into the semi-truck.
3. Whether the inevitable discovery doctrine prevented suppression of the evidence despite the unlawful entry.

Disposition

reversed_and_remanded